Demad For Documents Form 92 - E. Mitkova.doc

FORM 92 (RULE 26(1))

No. S004040 VANCOUVER REGISTRY

IN THE SUPREME COURT OF BRITISH COLUMBIA BETWEEN: TRACY KAPOUSTIN, NICHOLAS KAPOUSTIN BY HIS GUARDIAN AD LITEM TRACY KAPOUSTIN AND MICHAEL KAPOUSTIN PLAINTIFFS AND: THE HONOURABLE MURAVEI RADEV MINISTER OF FINANCE IN HIS OFFICIAL CAPACITY FOR REPUBLIC OF BULGARIA,

DEFENDANT and STEFCHO GEORGIEV, MARIO STOYANOV, EMILIA MITKOVA, KINA DIMITROVA, IVETA ANADOLSKA, DIMITAR SHACKLE and DEREK A. DOORNBOS, INDIVIDUAL DEFENDANTS

Demand For Discovery Of Documents

TAKE NOTICE that the Plaintiffs demand you Defendant Emilia Mitkova make discovery of all documents which are or have been in your possession or control relating to any matter in question in this action within 21 days from delivery of this demand by providing a list in Form 93. Plaintiffs rely further on the provisions of Rule 26(8) of the Court that you produce or make available for copying the following documents, inter alia, referred to in the Pleadings: 1. All original correspondence from or to Government of Canada, Royal Canadian Mounted Police and S. Sgt. Derek A. Doornbos from on or about 15 May 1995 to the present, including but not limited to, inter alia, typed or hand written notes, daily 1

diary entries, minutes of meetings, memorandums, directives, letters, agreements, telephone logs, faxes, telexes, teletype, telephone recordings or as electronic data. 2. All original correspondence to you or from you to any other Defendant in this action referring to the Plaintiffs personally or their assets, including, inter alia, typed or hand written notes, daily diary entries, minutes of meetings, memorandums, directives, letters, agreements, telephone logs, faxes, telexes, teletypes, telephone recordings or as electronic data. 3. Notes; directives; memos; reports; all private criminal complaints of embezzlement [Article 203, Criminal Code] as lodged up to and including 28 November 1995 and any audits in support of the accusation thereof; all private criminal complaints of misappropriation [Article 206, Criminal Code] as lodged up to and including 12 February 1996 and any audits in support thereof; all private criminal complaints of fraud [Article 211, Criminal Code] as lodged up to and including the available 12 February 1996 MPPO documents and evidence claimed by the Government of Bulgaria as proving the existence of, inter alia, 9065 victims of the embezzlement; 3400 statements of claim of witnesses against the Applicant as collected by MPPO by the aforesaid date; a 382 page computer report listing what the Government represented as 9000 fraudulent contracts proving Bulgarian citizens “deposited” 12,600,000 USD with the Applicant and further the Government produce a list of the names of “dead souls” [deceased Bulgarian citizens] claimed by the Government to the agencies of Interpol as proving a large amount of dirty [criminal] money have been laundered by Plaintiff Kapoustin. 4. Any other document referred or alluded to in the pleadings setout in the amended Statement of Claim. Dated at Vancouver this …………….. day of 2000.

________________________ On behalf of Plaintiffs

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